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Site Visit Report 

Alaska Seafood Processing Industry Petition Response 

Lindsay Guzzo 

Environmental Engineer 

U.S. Environmental Protection Agency 

Region 10 Permits Division 

guzzo.lindsay@epa.gov

206-553-0268 

 Betsy Bicknell 

 Senior Environmental Engineer 

 Eastern Research Group, Inc. (ERG) 

 betsy.bicknell@erg.com

 703-633-1612 

Plant Name Trident Seafoods 

Plant Address Kodiak, Alaska 

NPDES Permit # AKG528833 

Date of Visit Tuesday, August 17, 2010 

People Contacted Greg Hathaway, Plant Manager 

Roger Wagner, Assistant Plant 

Manager 

Jim Ewing, Corporate Quality 

Assurance 

Seafood processed Pollock 

Other groundfish (halibut, cod, rockfish, flatfish) 

Crab 

Salmon 

Products Fresh and frozen: 

 Whole fish (H&G) 

 Fillets 

 Surimi 

 Crab 

Range of annual production volume 50 to 60 million pounds/year 

Months of operation Year round, 250 to 350 days per year 

Discharge type Screened solids are trucked to Kodiak Fishmeal Company 

Screened wastewater is discharged through NPDES 

permitted outfall, meets O&G and TSS limits. 

Website http://www.tridentseafoods.com/ 

Trident’s Kodiak plant is built in and around the grounded vessel Star of Kodiak, the 

former liberty ship Albert M. Boe (Figures 1 and 2), which was brought to Kodiak to 

replace the plant that was completely destroyed by the 1964 tsunami. 

At the Kodiak plant, Trident processes relatively little salmon. Pollock is the major 

product and they process other groundfish, including halibut, cod, rockfish, and various 

flatfish. They also process some crab. They haven’t processed herring in 10 years, but 

may get some in 2011. They do not process shrimp. 

Trident Kodiak produces fresh and frozen products, in the form of headed and gutted 

(H&G) fish and fillets. They also make surimi from pollock. Trident managers estimated 

they use 1 MGD of city water. 

Operations. Fish are pumped off the fishing boats (Figure 3) and stored in refrigerated 

seawater (RSW) tanks (Figure 4) or pumped directly into the plant. Trident may also 
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unload fish using a brailer (an unloading apparatus with a rigid frame from which is 

suspended a net bag with a drawstring and trip device). Fish are added to the top and 

released through the bottom. Tanks hold 850,000 pounds and each boat’s catch is stored 

separately. Boats bring crab in totes which are unloaded from the boat and tipped into the 

plant’s crab hopper. 

Each boat’s catch is sorted by species to verify that only fish for which the fisherman has 

a valid permit (i.e., fish that he can legally catch) are processed for human consumption. 

Figure 5 shows the conveyer system for sorting fish. Fish that are removed from the 

catch are sent to the Kodiak Fishmeal Company and include out-of-season species, 

undersized fish that can’t be made into surimi, squid, jellyfish, and smelt. The 

temperature and weight of the legal catch is recorded and the fish are transferred to the 

processing plant. Figure 6 shows the flume chute that sends the fish into the processing 

center. 

Trident operates separate lines for cod, flatfish, and rockfish. These fish are headed, 

gutted, cleaned, and trimmed. Guts and trimmings are dropped into a tote or sluiced to 

floor drains that lead to a large sump in the basement. Figure 7 shows an overview of the 

processing floor. 

Roe from several species are separated from the guts and sold as separate products. In 

addition to salmon roe, which is sold in the U.S. and Europe, pollock roe, which is 

orange, is sold in Japan. Cod roe is graded by color and sold to Korea. Frozen cod heads 

are also shipped to Korea. 

In addition to the fish lines, Trident also operates a surimi line and processes live crabs. 

Crabs are cooked and shelled. Waste shell is separated from other wastes and totes of 

crab shells are trucked to the Kodiak Fishmeal Company plant. 

Surimi. Trident Kodiak makes two grades of surimi: 

 Top grade, made from fillets; and 

 Second grade, made from the flesh removed from the frames. 

Ground fish is passed through an Alfa-Laval two-phase decanter to separate solids 

(protein) from liquid. The solids are minced in a screw press and then forced through the 

holes in a refiner. Skin and bones are separated at this stage and discharged to waste. 

The liquid waste from the surimi line can reach a BOD5 concentration of 1,500 mg/L. 

During surimi production, Trident has samples of its wastewater analyzed for BOD5 by a 

third party laboratory (Kodiak Seafood Laboratories run by Chris Sanitto, who is also the 

QA Manager for Western Seafoods). The surimi line discharges about 300,000 gallons 

per day. Surimi is packed into 22 pound (10 kg) trays and frozen in the plate freezer 

Figure 8 shows a walk-in freezer while Figure 9 shows the rows of block freezers. . 

Shipping. Products are shipped from Kodiak by air or sea. A container ship leaves 

Kodiak twice a week, while a barge leaves once a month. Refrigerated vans of frozen 
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seafood are transported by ship and barge. Fresh fillets are shipped by air freight on 

Alaska Air. 

Waste Management. Fish waste is sluiced to a pit sump in the basement. Water and 

solids that accumulate in the sump are pumped to the roof level to an interior-feed 

rotating screen. Figure 10 shows the interior of the screen and Figure 11 shows an 

exterior view. The screen as a 1 mm mesh. The wastewater that flows through the screen 

is discharged through the plant’s NPDES permitted outfall, 200 feet from shore. The 

wastewater is periodically sampled and analyzed for TSS, O&G, and pH. Wastewater 

from surimi production is also analyzed for BOD5. The sampling port is shown in Figure 

12. Samples for O&G analysis are collected as grabs. Samples for the other analytes are 

collected as grab composites. Because permit limits are in pounds per day. Trident uses 

the metered incoming water flow and a calculation methodology provided in the permit 

to calculate the mass of pollutant discharged. Trident also meters the wastewater 

discharge. Figure 13 shows the effluent discharge pipes. 

According to the Trident managers, the rotary screen requires little maintenance. The 

bearing and drive train motor are inspected and lubricated annually. The screen is 20 

years old and has lots of remaining life. 

Solids screened from the wastewater flow are discharged from the end of the rotating 

screen into a hopper two levels below the screen (Figure 14). Trident hires a trucks to 

pick up waste and haul it to the Kodiak Fishmeal plant. The trucks are loaded directly 

from the hoppers. They come as often as needed to remove the waste solids, which may 

be every three hours when the plant is busy. The trucks are inspected by the state and 

DOT. The truck loading area and truck are covered to keep eagles and other birds from 

getting into the waste. When asked if citizens had any complaint about odor from the 

trucks, the Trident managers said no, but there have been complaints about the odor from 

the fishmeal plant. 

Compliance Concerns. Ms. Guzzo asked if Trident had any problems meeting their 

discharge limits or other compliance concerns. Jim Ewing mentioned that they had found 

inconsistency between laboratories analyzing samples for O&G. One lab measured high 

concentrations and the other measured no detectable concentration. 

Trident managers reported no problems complying with their discharge permit limits. 
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Figure 1. Stern, Star of Kodiak 

Figure 2. Star of Kodiak (former liberty ship SS Albert M Boe) 
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Figure 3. Fish pump hose 

Figure 4. Fish holding tank 
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Figure 5. Fish conveyor 
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Figure 6. Flume 

Figure 7. Overview 
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Figure 8. Freezer 
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Figure 9. Block freezers 
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Figure 10. Rotary screen 
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Figure 11. Rotary screen exterior 
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Figure 12. Sampling point 
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Figure 13. Effluent 
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Figure 14. Truck loading hopper